Environment

I N F O R M A T I O N F R O M K O D A K J-214 $18.00

The Regulation of Silver in

Photographic Processing Facilities Kodak’s health, safety,
and environmental
publications are available
to help you manage your
photographic processing
operations in a safe,
environmentally sound
and cost-effective
manner. This publication
is part of a series of

You will find regulations that apply
to silver and silver-bearing materials
in many of the environmental laws
that are administered by the United
States Environmental Protection
Agency (USEPA). These laws are
designed to protect air, water, and
land resources, and to provide
information about the chemicals
used, stored, and released to the
environment. Most state and local
agencies also regulate silver. In some
cases, state or local regulations
may be more stringent or include
additional requirements not found
in federal regulations.
The following is a review of
USEPA regulations that apply to
silver and silver-bearing materials
found in photographic processing
facilities. Check with your state or
local agencies to determine if
additional requirements apply to
your facility.
Silver and silver-bearing materials publications on silver
in a photographic processing facility
are typically regulated by the USEPA management designed
under the following federal laws:
• Resource Conservation and to help you optimize
Recovery Act (RCRA)
• Clean Water Act (CWA) silver recovery. It will
• Safe Drinking Water Act (SDWA) help you understand how
• Comprehensive Environmental
Response Compensation and silver is regulated and
Liability Act (CERCLA or
Superfund) how those regulations
• Emergency Planning and
Community Right-to-Know Act apply to your facility.
(EPCRA or SARA Title III)
Understanding how silver and
silver-bearing materials are regulated
by each of these laws will help you
determine how these laws affect
your facility. How you manage
Environmental
Services

This publication supersedes KODAK Publication

No. J-21, dated 9-90.

©Eastman Kodak Company, 1996

silver-bearing materials will
establish your specific regulatory
compliance requirements. These
requirements can range from fairly
simple and inexpensive activities
such as maintaining records, to
more costly and complex activities
such as analytical testing and
hazardous waste manifesting.
SILVER AND THE RESOURCE
CONSERVATION AND
RECOVERY ACT (RCRA)
The Resource Conservation and
Recovery Act (RCRA) protects
human health and the environment
by making sure that hazardous waste
management practices are conducted
in a sound manner. RCRA is a
cradle-to-grave system for tracking
and regulating hazardous waste
from the time it is generated to its
ultimate disposal.
A material must be defined as a
“solid” waste before it can be defined
as a hazardous waste. As defined by
RCRA, a solid waste can be a
liquid, semi-solid, sludge, or
contained gas. Solid wastes are
generally those materials that have
been used and discarded. However,
recycled materials can also be solid
wastes depending upon the nature of
the materials and the manner in
which they are recycled.
Once a material is defined as a
solid waste, it can further be classified
as either a listed or characteristic
hazardous waste. There are no listed
silver-bearing wastes generated by
a typical photographic processing
facility. Solid wastes that possess
certain characteristics, such as
containing greater than or equal
to 5 ppm of leachable silver, are
considered hazardous wastes due to
their toxicity characteristic (TC).
Leachability is determined for solid
2 The Regulation of Silver in Photographic Processing Facilities
materials using the Toxicity
Characteristic Leaching Procedure
(TCLP) which subjects the material
to a dilute acid solution. Liquid
wastes that contain greater than or
equal to 5 ppm of silver are also
classified as characteristic hazardous
wastes (EPA Hazardous Waste
Number D011).
Facilities that generate hazardous
waste are divided into different
categories depending on the amount
of hazardous waste that is generated.
These categories are determined by
“counting” the amount of hazardous
waste that is generated at a facility in
one month. Some silver-bearing
hazardous wastes are not counted
because they are managed in a
wastewater treatment unit or they
are not stored or accumulated.
Facilities that generate hazardous
waste are subject to a number of
requirements for the management
of their wastes depending on their
generator category. Silver-bearing
hazardous wastes that are reclaimed
to recover economically significant
amounts of silver are regulated under
specific provisions of RCRA. These
provisions include a limited number
of generator requirements and an
exemption from needing a RCRA
permit for the treatment of those
hazardous wastes.
Many states have been approved
by USEPA to operate their own
RCRA program. Most states
regulate the management of silver-
bearing hazardous wastes in the same
manner as USEPA; however, some
states may have more stringent
requirements. For example, some
states may have different generator
categories, or may include different
management requirements for
reclaiming silver from a hazardous
waste.
Compliance Requirements
To determine the compliance
requirements for your photographic
processing facility, you must identify
those materials at your facility that
could be classified as a hazardous
waste. Once you have identified those
materials, you must determine which
of them should be “counted” to
determine your generator category.
Certain silver-bearing materials may
be exempt or excluded based on
how they are generated or how they
are managed. Once you have deter-
mined your generator category,
then you can identify those compli-
ance requirements that apply to
silver-bearing hazardous wastes at
your facility.
While this section describes the
requirements for managing silver-
bearing hazardous wastes from
photographic processing facilities,
it is important to note that your
generator category is determined
by counting the total amount of
hazardous waste generated at your
facility. This total quantity also
includes other hazardous wastes
such as solvents from maintenance
operations or corrosive cleaning
liquids. The following federal
requirements apply only to the
silver-bearing hazardous wastes.
However, you should also be
familiar with regulations that apply
to other hazardous wastes generated
at your facility.
• J-214
 Identifying Silver-Bearing Hazardous Wastes
Material Hazardous Waste Determination
Photographic Representative samples of processed and unprocessed Kodak photographic films and
Films and Papers papers were tested using the TCLP. These samples did not leach silver at greater than
or equal to 5 ppm. Therefore, these materials would not be classified as a hazardous
waste for silver under RCRA by USEPA.
Photographic Unused photographic processing solutions do not contain silver and would therefore
Processing Solutions not be regulated as a silver-bearing hazardous waste when discarded or recycled.
Used photographic processing solutions that typically contain greater than 5 ppm of
silver include fixers, bleach-fixes, activators and low flow washes, as well as bleaches
and stabilizers from washless processes. Developers generally do not contain greater
than 5 ppm of silver; however in processes that have very high volume or employ
regeneration of developers, concentrations of silver can reach levels greater than
5 ppm. Washwaters can also develop concentrations of silver at levels greater than
5 ppm. This silver is usually the result of carry-over from the preceding tank.
Regenerated or Recycled Materials can be excluded from being a hazardous waste by being managed in a
Photographic Processing certain way, such as being reclaimed and returned to a process in a closed system.
Solutions This exclusion requires that the recovery process and associated storage be in fixed
tanks and that the materials be transferred to the recovery process using fixed piping.
Materials that are collected and transferred in portable containers do not qualify for this
exemption. Typical in-line electrolytic silver-recovery, ion-exchange washwater
treatment, and bleach-fix regeneration systems are examples of where the materials in
the recovery loop are not considered hazardous wastes unless they are removed from
the recovery process and contain ≥ 5 ppm silver.
Silver-Bearing Materials High-purity flake silver from electrolytic silver-recovery units is considered to be a
From Recovery product by the USEPA and is not regulated as a hazardous waste under RCRA when
sent for refining.
Other technologies used to recover silver, such as metallic replacement or precipitation,
are wastewater treatment units and result in the generation of silver-bearing materials
which are “sludges.” These materials are sludges because they are residues from
pollution-control processes. Characteristic sludges being reclaimed are exempt
from the definition of solid waste and therefore cannot be a hazardous waste. Silver-
bearing materials such as Metallic Replacement Cartridge (MRC) sludge or KODAK
Silver-Recovery Agent precipitate that are sent to a silver refiner to complete the
silver-recovery process are exempt from being classified as hazardous waste.
Photographic Filters used in photographic processors to remove particulate from processing
Processor Filters solutions can be a hazardous waste when disposed. Typically, the filters used for
silver-bearing solutions, such as fixers or bleach-fixes, leach greater than 5 ppm silver
when subjected to the TCLP. These materials can be rinsed prior to disposal or sent to
an off-site hazardous waste treatment facility. The rinse water should be collected and
treated in your silver-recovery system.

J-214 • The Regulation of Silver in Photographic Processing Facilities 3

Hazardous Waste Counting
If your photographic processing
facility generates hazardous waste, the
waste must be “counted” to deter-
mine your generator category. Your
generator category is determined
by the amount of hazardous waste
that is generated at your facility
each month. Some silver-bearing
hazardous wastes are not included in
the quantity determination because
of the way they are managed.

Silver-Bearing Hazardous Wastes Not Included in the Quantity Determination

Description
Hazardous wastes that are not stored or accumulated
at your facility.
Hazardous wastes that are:
• directly transferred to silver recovery through fixed piping
• stored only in fixed tanks
• discharged to a Publicly Owned Treatment Works
(POTW) after recovery (Wastewater Treatment Unit).
Hazardous wastes that are generated from treating a
waste that has already been counted.
Example
Wastes which are directly discharged, without storage
or accumulation, to a municipal sewer system. This
could include developers or washwaters that contained
> 5 ppm silver but are not collected or managed prior to
discharge.
Used fixer treated in flow-through terminal silver
recovery.
Rinse water from processor filters would not be counted
if the filters had already been counted.

Silver-Bearing Hazardous Wastes Included in the Quantity Determination

Description
Hazardous wastes that are stored or transported in
portable containers prior to on-site silver recovery.
Hazardous wastes that are transported off-site.
Processor filters that are hazardous wastes.
Example
Silver-bearing solutions that are collected in containers
and transported to the silver-recovery system in those
containers. This is the typical configuration in a minilab.
Used fixer that is transported to another facility to be
de-silvered.
Processor filters from fixer tanks.

4 The Regulation of Silver in Photographic Processing Facilities • J-214

Determining Your Generator
Category
Once you have identified all hazar-
dous wastes, and the appropriate
wastes have been counted in the
quantity determination, you can
determine your generator status.
USEPA currently identifies three
categories of generator status. These
categories are based on the amount
of hazardous waste generated
(counted) at a facility per month.
Once you exceed a monthly
threshold in a category, the entire
amount of hazardous waste at your
facility becomes subject to the
requirements of the next level of
generator (unless, of course, you
already qualify for the large quantity
generator). Make sure you include
all hazardous wastes generated at
your facility that are subject to
counting, and that the determination
is for a calendar month and is not an
average over several months. If the
quantity of hazardous waste
generated at your facility varies from
month to month, your generator
category may also change from
month to month. In those cases, the
highest status should be assumed to
ensure compliance at all times.
There may also be limitations
on the amount of hazardous wastes
and the duration of storage for each
generator category. If you exceed
the maximum amount of storage or
accumulation time in a category,
your facility would be regulated as
the next highest generator category.

Hazardous Waste Generators

Amount Generated
Generator Category per Month
Conditionally Exempt Small Quantity < 100 kg/month
Generator (CESQG) (~ 27 gallons)
Small Quantity Generator (SQG) 100 –1000 kg/month
(~ 27–270 gallons)
Large Quantity Generator (LQG) > 1000 kg/month (~ 270 gallons)

Hazardous Waste Storage Restrictions

Maximum Amount Maximum On-Site
Generator Category Stored On-Site Accumulation Time
Conditionally Exempt Small Quantity 1000 kg No Limit
Generator (CESQG) (~ 270 gallons)
Small Quantity Generator (SQG)* 6000 kg 180 Days
(~ 1620 gallons) (270 days if treatment facility
is more than 200 miles away)
Large Quantity Generator (LQG)* No Limit 90 Days
(without RCRA permit)
*Silver-bearing hazardous wastes that are reclaimed to recover economically
significant amounts of silver generated by SQG and LQG are not subject to
on-site storage limits and can be stored on-site for up to one year.

J-214 • The Regulation of Silver in Photographic Processing Facilities 5

Generator Requirements
Once you have determined your
generator category, you can identify
the compliance requirements for
managing silver-bearing hazardous
wastes at your photographic
processing facility. Large Quantity
Generators (LQG’s) and Small
Quantity Generators (SQG’s) of
silver-bearing hazardous wastes that
are reclaimed to recover economi-
cally significant amounts of silver are
subject to specific provisions under
RCRA. Conditionally Exempt
Small Quantity Generators
(CESQG’s) are not subject to those
provisions; rather they are subject to
fewer requirements based on their
smaller size.
6 The Regulation of Silver in Photographic Processing Facilities
Conditionally Exempt Small
Quantity Generators
If you qualify as a Conditionally
Exempt Small Quantity Generator
(CESQG), you may treat hazardous
wastes on-site or you must ensure
delivery to an appropriate facility
for treatment or disposal. CESQG’s
are not required by USEPA to have
an EPA ID number, use a hazardous
waste manifest for the transportation
of their wastes to an off-site treatment
or disposal facility, or to keep records
of waste management activities.
Small Quantity Generators and
Large Quantity Generators
Hazardous wastes—generated by
SQG’s and LQG’s—that are
reclaimed to recover silver are subject
to a specific set of regulations. The
requirements include notification,
use of manifests, and recordkeeping.
Hazardous waste treatment permits
are not required by USEPA for
silver-recovery operations. Non-
silver-bearing hazardous wastes and
silver-bearing hazardous wastes that
are not reclaimed would be subject
to full regulation under RCRA.
• J-214
 Generator Requirements for Silver-Bearing Hazardous Wastes That are Reclaimed
Requirement CESQG SQG LQG
EPA ID Number Not Required Notify USEPA or your state agency of your hazardous waste management activities
by completing EPA Form #8700-12. Upon receipt, the agency will assign your facility
an EPA ID Number.
Manifests* Not Required Required for all off-site transportation Required for all off-site transportation of
of silver-bearing hazardous wastes silver-bearing hazardous wastes.
performed without a contractual
agreement to recycle and return the
material.
SQG’s are not required to use manifests
for the transportation of silver-bearing
hazardous wastes to a recycling facility
if the waste is reclaimed under a
contractual agreement that specifies
waste type and frequency of shipments.
The vehicle used to transport the waste
to the recycling facility must be owned
and operated by the reclaimer. The
recycled material must be returned to the
SQG for reuse. The SQG must maintain
a copy of the reclamation agreement for
a period of three years after termination
or expiration of the contract.
SQG’s/LQG’s who perform their own transportation must also use a manifest. The
transporter’s signature must be on the manifest prior to shipping. Signed copies of
manifests must be retained for a period of three years. A copy of the completed
manifest should be returned to the SQG within thirty days of receipt by the treatment
or disposal facility.
Recordkeeping Not Required SQG’s/LQG’s who store silver-bearing hazardous wastes prior to reclamation must
keep records to document that they are not speculatively accumulating by
accumulating more than 25% of the materials in a calendar year without reclaiming
the silver. Most silver-recovery operations are performed shortly after materials are
generated and, therefore, no materials would accumulate during the calendar year.
Records must show volume of materials on-site at the beginning of the year
(January 1), volume of materials generated during the calendar year, and volume of
material on-site at the end of the calendar year. These records must be kept for a
period of three years.
On-Site Storage Up to 1000 kg may be No on-site quantity limitations.
Restrictions accumulated on-site with Land Disposal Restrictions require on-site storage of silver-bearing hazardous wastes
no time limitations. be limited to less than one year.
Land Disposal Not Required SQG’s/LQG’s must keep a one-time notice on file that states:
Restrictions Notice This facility generates a hazardous waste that is restricted under the Land Disposal
Restrictions (LDR). Silver from these wastes is reclaimed under 40 CFR, Part 266,
Subpart F. All silver-bearing restricted wastes are reclaimed on-site or sent for
off-site treatment.

J-214 • The Regulation of Silver in Photographic Processing Facilities 7

SILVER AND THE CLEAN
WATER ACT (CWA)
The goal of the Clean Water Act
(CWA) is to minimize the discharge
of pollutants to surface waters.
This Act prohibits the discharge of
pollutants directly into surface waters
except in compliance with a National
Pollution Discharge Elimination
System (NPDES) permit. Wastewater
treatment facilities or Publicly
Owned Treatment Works (POTW)
must have NPDES permits that
establish discharge limits for the
POTW’s effluent quality. A photo-
graphic processing facility that
discharges directly to surface water
must also have a NPDES permit.
Silver is classified as a “priority
pollutant” under the CWA, and the
discharge of silver is regulated by
many NPDES permits. The discharge
limitation of silver in a NPDES
permit is often based on state water
quality standards for silver. Water
quality standards can vary greatly
depending on the stringency of the
state’s standards and the use of the
water. These differences, coupled
with design and wastewater loading
variations at each POTW, result in
the need for site-specific silver
limitations in each NPDES permit.
These limits for silver are typically
well below concentrations achievable
using the best available silver-recovery
technologies, making it virtually
impossible for a photographic
processing facility to directly discharge
photographic processing effluents to
surface waters.
8 The Regulation of Silver in Photographic Processing Facilities
Most photographic processing
facilities discharge their wastewater
to a municipal sewer collection
system that conveys the material to
the POTW for further treatment.
The POTW must limit the chemical
constituents in the incoming waste-
water to ensure that the treatment
plant will be able to maintain
compliance with their NPDES
permit. These limitations are
referred to as pretreatment standards
or sewer use codes. Each POTW
has its own pretreatment standards
or sewer use codes that are unique
to its regulatory situation. Silver is
usually regulated in discharges from
photographic processing facilities at
concentrations that require silver
recovery prior to discharge.
Compliance Requirements
To determine your sewer discharge
compliance requirements, you must
identify all materials that your
photographic processing facility
discharges to a POTW. You may
need a discharge (pretreatment)
permit or approval from the POTW.
Specific compliance requirements,
such as analytical testing or reporting,
may also be included in the permit
or authorization.
Discharge Permits
If your facility does not have a
wastewater discharge permit or you
are unsure if a permit is required,
you should contact the wastewater
treatment authority that manages
the POTW. Some states also have
their own pretreatment permitting
program in conjunction with the
wastewater treatment authority.
The POTW will need to know that
your facility performs photographic
processing and the volume of waste-
water that you are discharging. You
should also request a copy of the
local sewer use code that applies to
your facility.
Some wastewater treatment
authorities will require you to
complete a discharge survey or
application before they will issue
a permit. If your facility is not
required to obtain a wastewater
discharge permit, request a letter
that specifically states that no
permit is required. Ask the authority
to notify you when a change is
proposed to the wastewater discharge
requirements for your facility.
Silver Discharge Limits
In addition to understanding your
POTW’s permitting requirements,
you should also determine what
pretreatment limits in the local
sewer code apply to your photo-
graphic processing facility. Silver is
commonly regulated with restrictive
discharge limits.
If the POTW regulates silver in
the pretreatment program, you may
be required to demonstrate compli-
ance by periodically collecting
samples of the photoprocessing
effluents for analysis. Sample
collection points for photoprocessing
effluent will often be specified in
your wastewater pretreatment
discharge code or permit. If no
sampling point is specified, sample at
a point where all the facility’s waste-
water is collected and discharged.
This point will result in a sample that
is representative of the total discharge
from the entire facility.
• J-214
Wastewater Sampling
The type of sample required is also
important. A grab sample is a single
one-time sample. This type of
sample can be a good indicator of
the character of the wastewater. For
processes that are not continuous,
such as batch silver recovery, this
sampling technique may not be
representative of the actual total
discharge. A composite sample is the
accumulation of a series of grab
samples collected at regular intervals
over a long period of time, usually
24 hours. The interval of sampling
can be either proportional to time or
flow. Most photographic processing
facilities do not run a 24-hour
continuous business, therefore a flow-
proportional composite sample will
result in a sample that most accurately
characterizes the discharge.
Silver Analysis
Silver can be measured in several
ways. The most common is through
an analytical method known as
total recoverable silver. This method
measures all silver that is present in a
sample. Some POTWs may require
dissolved silver to be measured or may
include a translator to estimate the
portion of dissolved silver from a
total measurement. It is important
that you determine which analysis is
required and request the appropriate
analysis from your analytical
laboratory.
Keep records of all monitoring
and sampling results for three years.
J-214 • The Regulation of Silver in Photographic Processing Facilities
Analytical Laboratories
Because of the complexity of
analyzing silver, you must be
careful when selecting an analytical
laboratory to perform silver analysis.
The laboratory you select should
have a good understanding of, and
experience in, analyzing silver.
Some states require certification of
laboratories that perform analysis for
regulatory compliance. Make sure
you are using a certified laboratory
if your state requires certification.
Environmental Analytical Services
from Kodak make the testing and
analysis process simple, economical,
and accurate. You can benefit from
Kodak’s extensive expertise in
analyzing complex photographic
processing solutions and effluents.
Strict adherence to EPA-approved
testing methods and laboratory
certification yield accurate analytical
results that you can submit for
regulatory compliance demonstration
purposes in most states.
For more information about
Environmental Analytical Services
from Kodak, call 1-800-283-4173.
Discharges of Hazardous Wastes
If the wastewater you are discharging
to your local POTW has a concen-
tration greater than or equal to
5 ppm of silver at the point where it
leaves your facility and enters the
sewer system, and you are discharging
more than 15 kilograms/month of
hazardous waste, you must submit a
one-time written notification to
your local POTW, the USEPA, and
your state hazardous waste authority.
This notification must include:
• Hazardous waste name (i.e. silver)
• EPA hazardous waste number
(i.e. D011)
• Type of discharge (e.g. continuous,
batch), and
• Certification that a waste minimiza-
tion program exists, to the extent
that it is economically practical, to
reduce the volume and toxicity of
hazardous wastes generated.
If the discharge is greater than
100 kg/month, the notification must
also include:
• Identification of the hazardous
constituents in the waste
• An estimate of the mass and
concentration of the hazardous
constituents discharged, and
• An estimate of the mass of the
constituents in the waste stream
expected to be discharged during
the course of the following year.
9
SILVER AND THE SAFE
DRINKING WATER ACT (SDWA)
The Safe Drinking Water Act
(SDWA) establishes standards for
drinking water quality and regulates
the underground injection of wastes
and other substances that could
contaminate underground drinking
water sources. Discharges to septic
tanks are regulated under the
SDWA’s Underground Injection
Control Program (UIC). An UIC
permit is required for discharges to
a septic system from commercial
establishments. Effluents from
photographic processing facilities
are not typically allowed to be
discharged to septic tanks under an
UIC permit.
In addition, some states regulate
groundwaters also under their CWA
laws. Discharges to a septic system in
those states may also be regulated
through NPDES permits.
Compliance Requirements
If your photographic processing
facility uses septic tanks for disposal
of silver-bearing wastes, contact your
state or local environmental agency
to determine the specific permitting
and compliance requirements.
If your photographic processing
facility is not allowed to use a septic
tank system for disposal, you should
have your photographic effluents
transported off-site for treatment
or disposal.
10
SILVER AND THE COMPREHENSIVE
ENVIRONMENTAL RESPONSE
COMPENSATION AND LIABILITY
ACT (CERCLA OR SUPERFUND)
The Comprehensive Environmental
Response Compensation and
Liability Act (CERCLA) was created
to control and regulate the cleanup
of environmental contamination.
This includes cleanup of existing
contamination from past disposal
practices and a system of reporting
and management of environmental
releases as they occur. CERCLA has
been called “Superfund” because
of the large amounts of money
appropriated by Congress to clean
up abandoned landfills.
Under CERCLA, silver-bearing
hazardous wastes are designated as
hazardous substances with a reportable
quantity (RQ) equal to 1 pound
(0.454 kg). You must report a
release that exceeds the RQ in a
24-hour period.
The Regulation of Silver in Photographic Processing Facilities
Compliance Requirements
If your photographic processing
facility spills or releases one pound
or more of a silver-bearing
hazardous waste solution into the
environment over a 24-hour period,
you must immediately notify the
National Response Center (NRC)
at 800-424-8802. The NRC or the
designated response agency will also
require cleanup of the release and a
follow-up report.
You are not required to report
releases to permitted facilities, such
as POTW’s, under CERCLA.
However, you should check with
your local POTW to determine
when and at what quantity they
recommend notification for spills
of silver-bearing photographic
processing solutions. Some local
sewer discharge regulations may
also contain spill reporting and
prevention requirements.
• J-214
SILVER AND THE EMERGENCY
PLANNING AND COMMUNITY
RIGHT-TO-KNOW ACT
(EPCRA OR SARA TITLE III)
The Emergency Planning and
Community Right-to-Know Act
(EPCRA) is often referred to as
SARA Title III. Although EPCRA
is a free-standing law, it is commonly
called SARA Title III because it
was the third title (or section) of
the Superfund Amendments and
Reauthorization Act (SARA).
EPCRA was created to make infor-
mation available to the public so that
local communities could plan for an
emergency in the event of a release
of a toxic chemical. Silver and silver
compounds are designated as toxic
chemicals under this law.
Certain facilities are currently
required to report information about
releases of toxic chemicals. Printing
and publishing facilities (SIC Codes
2711-2796) are the only photographic
processing facilities that are currently
required to report annually about
chemical releases.
The storage of extremely
hazardous substances can also
trigger notification requirements for
photographic processing facilities.
Silver or silver compounds are not
identified as extremely hazardous
substances.
Compliance Requirements
Most photographic processing
facilities do not have compliance
requirements under EPCRA.
Printing and publishing facilities
should include any storage of silver-
bearing materials in determining
reporting requirements.
J-214 • The Regulation of Silver in Photographic Processing Facilities
MORE INFORMATION
If you have environmental questions Information, with $1 to Eastman
about Kodak products or services, or Kodak Company, Department
for more information about Kodak 412-L, Rochester, New York
off-site waste management or refining 14650-0532.
services, contact Kodak Environ- The following publications are
mental Services at 1-585-477-3194, available from dealers who sell Kodak
between 8 a.m. and 5 p.m. (Eastern products, or you can order them
time). directly from Kodak through the
Kodak also maintains a 24-hour order form in KODAK Publication
health and safety hotline to answer No. L-1.
questions about handling photo- J-210 Sources of Silver in
graphic chemicals. If you spill a Photographic Processing
chemical or come into contact with Facilities
chemicals, call 1-585-722-5151.
J-211 Measuring Silver in
In countries other than the U.S.
Photographic Processing
and Canada, contact Kodak in
Facilities
your country.
Kodak has many publications to J-212 The Technology of Silver
assist you with information on Kodak Recovery for Photographic
products, equipment, and methods. Processing Facilities
To obtain a list of Kodak publica- J-213 Refining Silver Recovered from
tions, send your request for a copy Photographic Processing
of KODAK Publication No. L-1, Facilities
KODAK Index to Photographic
Kodak Information Center’s Faxback System
—Available 24 hours a day, 7 days a week—
Many technical support publications for Kodak products can be sent to your
fax machine from the Kodak Information Center. Call:
Canada 1-800-295-5531
If you have questions about Kodak products, call Kodak.
In the U.S.A.: 1-800-242-2424, Ext. 60, Monday–Friday, 8 a.m.–8 p.m. (Eastern time)
In Canada: 1-800-465-6325, Monday–Friday, 8:30 a.m.–5 p.m. (Eastern time)
Or contact Kodak on-line at: http://www.kodak.com/
11
Environmental
Services

This publication is a guide to the Federal Environmental Regulations

that apply to a typical photographic processing facility. Local or state
requirements may also apply. Verify the specific requirements for your
facility with your legal counsel.

This publication is printed on recycled paper that contains

50 percent recycled fiber and 10 percent post-consumer material.

EASTMAN KODAK COMPANY • ROCHESTER, NY 14650

Minor Revision 10-00

Kodak and “e” mark are trademarks. Printed in U.S.A.